In addition to the challenges of MiFID II, asset managers must also prepare for a new key information document regime for retail products. The Regulation on key information documents for packaged retail and insurance-based investment products (Regulation 1286/2014) (more widely known as “PRIIPs”, and referred to here as the “Regulation”) has been labeled “arguably the most extensive and complex joint work stream that has been tackled by the European Supervisory Authorities (ESAs)”. The Regulation cuts across different sector-specific initiatives in order to improve and consolidate the EU regulatory framework for pre-contractual disclosures to retail investors, and seeks to enable retail investors to understand better and compare the financial products available to them within the EU.

While PRIIPs is aimed at the European retail market for insurance and fund products, it is relevant to any alternative fund manager who may market its products to individuals or entities in Europe who come within the definition of a retail investor.

This Regulation will apply to producers and distributors of PRIIPs that are sold to retail investors in the EU regardless of their jurisdiction, and as such may have a significant impact on non-EU managers.